Private Client analysis: For several years corporations have used captive insurance companies to provide risk mitigation. High net worth (HNW) families have varying significant assets that are required to be insured and those families should be able to utilize captive insurance companies to provide them with risk mitigation, and a transfer of assets to future generations. Because captives are licensed, regulated entities, they are legally independent from any other entities. This permits the formation of captives in executing a long-term estate plan or to protect certain assets. Written by Wayne Fields, President, and Justin Cole, Vice President of the DGM Financial Group in Barbados.

Law360, Expert analysis: The pace of artificial intelligence technology integration into UK businesses is rapidly increasing and providing unquestionable efficiency benefits to businesses. Josianne El Antoury, special counsel, at Covington & Burling LLP summarises some of the UK’s concerns as they relate to generative AI, a new category of AI tools, and some potential insurance coverage solutions for those risks.

This Practice Note describes the basic rules which determine how gains and losses arising from a company’s intangible fixed assets (IFAs) are computed and then brought into account for corporation tax purposes under the corporate intangible assets regime in Part 8 of the Corporation Tax Act 2009 (CTA 2009). Generally, the taxation of IFAs under the corporate intangible assets regime: • is based on accounting gains and losses credited to, or charged against, profits in the company’s accounts drawn up in accordance with generally accepted accounting principles. But this is subject to specific tax provisions in CTA 2009, Pt 8 which depart from the accounting treatment • overrides the general corporation tax computational rules and takes precedence over other parts of the corporation tax code • refers to the amounts that are taken into account for corporation tax purposes as ‘debits’ (ie deductible expenses) and ‘credits’ (ie taxable receipts), and • brings taxable credits and deductible debits into account for corporation tax purposes as revenue (rather than capital) matters This Practice Note

The general rule under the corporate intangible assets regime in Part 8 of the Corporation Tax Act 2009 (CTA 2009) is that a company’s gains and losses in respect of its intangible fixed assets (IFAs) are computed and brought into account as credits and debits for corporation tax purposes in line with the accounting treatment of those IFAs. In other words, a company’s accounts, prepared in compliance with generally accepted accounting practice (GAAP), provide the basis from which the taxable and relievable items and amounts in respect of a company’s IFAs are derived. This principle is often referred to as ‘tax following the accounts’. There are, however, several exceptions to this general principle where the corporate intangible assets rules prescribe a departure from the accounts and require IFA credits and debits to be calculated on a different basis. For more on the tax treatment of IFAs generally, see Practice Note: How intangible fixed assets are taxed—basic principles. One area where the tax rules depart from reliance on the company's accounts

The general rule under the corporate intangible assets regime in Part 8 of the Corporation Tax Act 2009 (CTA 2009) is that a company’s gains and losses in respect of its intangible fixed assets (IFAs) are computed and brought into account as credits and debits for corporation tax purposes in line with the accounting treatment of those IFAs. In other words, a company’s accounts, prepared in compliance with generally accepted accounting practice (GAAP), provide the basis from which the taxable and relievable items and amounts in respect of a company’s IFAs are derived. This principle is often referred to as ‘tax following the accounts’. There are, however, several exceptions to this general principle where the corporate intangible assets rules prescribe a departure from the accounts and require IFA credits and debits to be calculated on a different basis. For more on the tax treatment of IFAs generally, see Practice Note: How intangible fixed assets are taxed—basic principles. One area where the tax rules depart from reliance on the company's accounts is where an IFA is a ‘restricted

Law360: With the Trump administration's emphasis on tariffs, including introducing tariffs against the U.S.' three biggest trading partners and advocating for an External Revenue Service to collect tariffs and other foreign revenue, members of the business world face increasing uncertainties as they assess and renegotiate the cost of doing business and obligations under a changed economic and political landscape, increasing the likelihood of contract disputes.[1]

Construction analysis: Dominic Sinnott of Gowling WLG considers how Artificial Intelligence (AI) is rapidly emerging as one of the most transformative technological developments in history. It is already impacting how we live, work and interact with the world; and it is continuing to develop at an extraordinary pace.

In order to claim Business Property Relief (BPR), the personal representatives of the deceased will need to complete form IHT413 (Business and partnership interests and assets) for each business asset for which BPR is to be claimed—see

Prioritisation of applications The Civil Aviation Authority (CAA) has confirmed that it will prioritise applications for Operating Safety Cases in respect of operations related to coronavirus. Under normal circumstances only applications from the police, fire or ambulance services are prioritised, with all other applications being reviewed on a first come, first served basis. Applications for the use of unmanned aircraft systems (UAS) for work related to coronavirus will also be prioritised, with those that have the most potential to mitigate harm from the outbreak being given the highest priority. However, there are limitations, as only applications from operators who have had their services specifically requested by one of the following organisations in relation to coronavirus will be assessed: • UK National Health Service Hospital or NHS Trust • UK Police Service • UK Fire Service • UK Ambulance Services, or • applications that have been specifically recommended/requested by a government department The CAA has also stipulated that it cannot guarantee the prioritisation of any application and that the processing times for applications relating to

On 26 March 2021 Companies House announced that the automatic filing extensions granted by the Corporate Insolvency and Governance Act (CIGA) 2020 for filing deadlines between 27 June 2020 and 5 April 2021, to relieve the burden on companies during the coronavirus (COVID-19) pandemic, will come to an end for filing deadlines that fall after 5 April 2021. For confirmation statement filings, accounts filings and event-driven filings after 5 April 2021, there will be no further automatic extensions and any deadlines that fall after this date will go back to normal. For mortgage charges, while those with an interest in the charge created up to and including 4 April 2021 will continue to receive an automatic extension of ten additional days to file the particulars of a charge, those with an interest in the charge created after 4 April 2021 will need to file within 21 days as normal. Companies that are eligible and cite coronavirus issues in their application can still apply for a three-month extension for accounts filing

Costs budgeting is the court’s way of controlling estimated future costs on a case. Where the costs of an application have been incurred prior to completion of the costs budget in respect of distinct applications such as an application for an injunction, the first thing to do would be to determine whether there is a costs order in place which covers the costs of this part of the proceedings and if so, whether the costs were summarily assessed. Where there is a costs order as to costs previously incurred If summarily assessed, such incurred costs can be added into the front page of Precedent H as being excluded, ie add to the ‘complete as appropriate’ box: ‘This estimate excludes VAT (if applicable), success fees and ATE insurance premiums (if applicable), costs of detailed assessment, costs of any appeals, costs of enforcing any judgment and

The assignment of a lease is generally treated in the same way as the transfer of a freehold interest and any payment or premium on the assignment (other than a reverse premium) will be subject to stamp duty land tax (SDLT) at the